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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N7591999-10-18018 October 1999 Provides Monthly Update on Progress of Installation of Seismic Upgrade Mods to Bldgs C-331 & C-335 ML20217M3861999-10-15015 October 1999 Provides Addl Changes to SAR Update Certificate Amend Request,Containing Changes That Resulted from re-evaluation of Autoclave head-to-shell O-ring Leakage Analysis Provided by DOE SAR Repts ML20217G1811999-10-14014 October 1999 Forwards Reissued Amend to Coc for Usec Paducah Gdp.Coc Corrects Coc Issued on 991006.Amend Number & Effective Date Were Inadvertently Incorporated as 3 & 991026,instead of 4 & 991105 ML20217G1731999-10-14014 October 1999 Requests Addl Info Re Applications Dtd 990924,requesting Amends to Cocs for Paducah & Portsmouth GDPs for Revised QA Programs.Encl Identifies Specific Info Needed.Info Should Be Provided within 30 Days ML20217F6801999-10-12012 October 1999 Forwards Updated Paducah GDP Certificate Amend Requests at NRC for Approval ML20217B3521999-10-0606 October 1999 Forwards Amend 3 to Certificate of Compliance GDP-1 to Revise Six Technical Safety Requirements Sections.Sections Are 2.1.4.17,2.1.4.8,2.3.4.1,2.3.4.4,2.3.4.16 & 3.10.4.b. Compliance Evaluation Rept Also Encl ML20217B2801999-10-0606 October 1999 Forwards Insp Rept 70-7001/99-203 on 990921-23.No Violations Noted ML20212K8941999-10-0404 October 1999 Forwards Insp Rept 70-7001/99-10 on 990720-0907 & Forwards NOV Indicating That Some Personnel Were Incorrectly Granted Unescorted Access to Controlled Access Areas Without Having Necessary Specific Training ML20216J8931999-10-0101 October 1999 Forwards Copy of Security Incident Log & Associated Info for Sept 1999 ML20216J9081999-09-30030 September 1999 Forwards Revised Written Event Rept 99-10,rev 3,pertaining to Corroded Fire Sprinkler Heads Affecting Operability of high-pressure Fire Water (HPFW) Sprinkler Sys.No Commitment Contained in Rept ML20217M3701999-09-29029 September 1999 Submits bi-monthly Update on Progress of Mods to Upgrade Audibility of Criticality Accident Alarm Sys (Caas).Schedule for CAAS Audibility Upgrades Attached ML20212H1251999-09-24024 September 1999 Notifies NRC of Change in Regulatory Commitments Associated with Submittal Date for Update of Application SAR Chapter 3.Specifics of Commitment Changes of Listed ML20212H3801999-09-24024 September 1999 Responds to 990723 RAI Re 1999 Annual Update to Certification Applications ML20212H3721999-09-22022 September 1999 Forwards NRC Form 790 Classification Record Documents for Paducah & Portsmouth GDPs That Were Generated During Month of Aug 1999.Without Encl ML20212F0981999-09-22022 September 1999 Forwards Insp Rept 70-7001/99-12 on 990830-0902.Purpose of Insp Was to Determine If Security Requirements Adequately Implemented & Included Review of Approved Plant Security Plan.No Violations Identified ML20217J1211999-09-20020 September 1999 Submits Listed Comments on NRC Proposed Rule, Reporting Requirements for Nuclear Power Reactors ML20212D4291999-09-17017 September 1999 Forwards Required 30-day Written Event Rept Re Criticality Accident Alarm Sys Response Time in Bldg C-710.Encl 2 Contains Commitments Contained in Submittal ML20212D4231999-09-16016 September 1999 Informs That Review of Event Rept Er 99-12 Revealed Listed Two Statements Inadvertently Omitted from Document ML20212D2361999-09-15015 September 1999 Submits Monthly Update on Progress of Installation of Seismic Upgrade Mods to Bldgs C-331 & C-335 ML20212B6611999-09-15015 September 1999 Forwards Insp Rept 70-7001/99-202 on 990816-20.No Violations Noted ML20212A5441999-09-14014 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/99-07 ML20212A5531999-09-14014 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/99-08 ML20211Q9951999-09-10010 September 1999 Forwards 30-day Written Rept ER-99-12,re Loss of Power to Autoclave Position 1 North & 1 South Process Gas Leak Detection (Pgld) in Bldg C-333-A.Caused by Electrical Short Circuit.Submitted Work Request 501636 for PI SEX-4 ML20216E4891999-09-0909 September 1999 Responds to Violations Noted in Insp Rept 70-7001/99-08. Corrective Actions:On 990602 Responsible Organization Manager Met with FP Engineer Performing Bldg Reappraisal & Made Clear Expectation for Prompt Reporting of Deficiencies ML20211P2091999-09-0909 September 1999 Provides Staff Written Clarification of NRC Reporting Expectations of When Double Contingency Losses Should Be Reported to NRC IAW Bulletin 91-001, Reporting Loss of Criticality Safety Controls, & Suppl ML20211P3831999-09-0303 September 1999 Forwards Coc GDP-1,amend 3 & Coc GDP-2,amend 4 for Paducah (Pgdp) & Portsmouth (Ports) Gdps,Respectively by Revising Pgdp & Ports QAPs in Vol 3 of Respective Certificate Applications ML20211L6441999-09-0202 September 1999 Forwards Insp Rept 70-7001/99-11 on 990802-06.No Violations Noted.Insp Consisted of Selective Exam of Procedures & Representative Records,Interviews with Personnel & Observations of Activities in Progress ML20211M3551999-09-0101 September 1999 Forwards Copy of Security Incident Log & Associated Info for Month of Aug 1999,IAW 10CFR95.57(b) ML20211K4041999-08-31031 August 1999 Forwards Responses to Remaining NRC Questions/Comments from 980601 & 0709 NRC RAIs Re SAR Update ML20211M7031999-08-30030 August 1999 Forwards Proprietary Rev 0 to Arming & Arrest Authority Security Plan for Paducah & Portsmouth Gaseous Diffusion Plants, for Review & Approval.Encl Withheld ML20211G9971999-08-26026 August 1999 Forwards Rev 2 to Written Rept Er 99-10,re Corroded Fire Sprinkler Sys in Bldg C-337 & C-333.Analysis of Root Cause Has Not Been Completed.Statistically Based Sprinkler head- Sampling Plan Has Been Completed & Approved ML20211B5021999-08-20020 August 1999 Forwards Amend 2 to Certificate of Compliances GDP-1, Revising Paducah GDP Technical Safety Requirements Re Audibility Requirements for Criticality Accident Alarm Sys at Facility & Related Sections of SAR ML20211F1761999-08-20020 August 1999 Requests That Paducah GDP facility,C-709 Lab Annex Bldg Be Added to List of Facilities to Be Exempted from CAAS Detection Coverage ML20211D9751999-08-20020 August 1999 Forwards Rev 1 to Final Written Event Rept Er 99-11,re Unplanned Actuation of C-333-A Autoclave 1 North Autoclave Steam Pressure Control Sys (Aspcs) on 990623 ML20211A7011999-08-17017 August 1999 Forwards Copy of Final Amend to 10CFR76 for Info of Subcommittee.Final Rule Is Being Transmitted to Fr for Publication.Final Rule Will Amend Regulations That Apply to Paducah & Portsmouth Gaseous Diffusion Plants ML20211D5811999-08-16016 August 1999 Submits Monthly Update on Progress of Installation of Seismic Upgrade Mods to Bldgs C-331 & C-335 ML20210P7421999-08-10010 August 1999 Forwards Insp Rept 70-7001/99-08 on 990529-0719 & Nov. Violations of Concern Because Late Reporting of Problems with safety-related Equipment Could Negatively Impact Continued Availability of Equipment ML20210Q6061999-08-0909 August 1999 Forwards NRC Form 790 Classification Record Documents for Paducah & Portsmouth Gdps,Per 10CFR95.57.Records Were Generated During Month of July 1999.Without Encl ML20210L6571999-08-0404 August 1999 Informs That Staff Completed Initial Review of 990720 Application to Amend Coc GDP-1.Staff Anticipates Completing Review by 990930 ML20211A7901999-08-0404 August 1999 Forwards Info Requested During Briefing by NRC Staff on 990726 Re NRC Interactions with Usec ML20210H3161999-07-30030 July 1999 Forwards Rev 1 to Written Event Rept ER-99-10,re Corroded Fire Sprinkler Heads Affecting Operability of HP Fire Water Sprinkler Sys in Bldg C-337 & C-333.Testing & Analysis of Root Cause & Corrective Actions Necessary Are Not Complete ML20210J1331999-07-30030 July 1999 Forwards Copy of Security Incident Log & Associated Info for Month of July 1999,per Reporting Requirements of 10CFR95.57(b) ML20210H2181999-07-29029 July 1999 Responds to Violations Noted in Insp Rept 70-7001/99-07. Corrective Actions:Smoke Watch Was Established Covering Area Affected by Process Gas Leak Detection Inoperabilty & Individuals Involved Were Counseled for Personnel Errors ML20210P7871999-07-29029 July 1999 Provides bi-monthly Update on Progress of Modifications to Upgrade Audibility of Criticality Accident Alarm Sys,In Response to NRC 981217 Request ML20210F9761999-07-28028 July 1999 Forwards Compliance Evaluation Rept Prepared to Support Amend of Coc GDP-1 Re Criticality Accident Alarm Sys Audibility.Notice of Amend Forwarded to Ofc of Fr Also Encl ML20210J7921999-07-27027 July 1999 Forwards Proprietary NRC Form 327, Special Nuclear Matl (SNM) & Source Matl (SM) Physical Inventory Summary Rept, for Paducah & Portsmouth Gdps.Rept Covers Period Ending 990528.Proprietary Info Withheld,Per 10CFR2.790(d) ML20210G0391999-07-26026 July 1999 Forwards Compliance Evaluation Rept & Fr Notice for Revised Qaps,Per 990212 Application ML20210H6001999-07-26026 July 1999 Forwards NRC Form 790 Classification Record Documents for Paducah & Portsmouth Gaseous Diffusion Plants That Were Generated During Month of June 1999.Without Encl ML20210D8181999-07-23023 July 1999 Submits Response to SA Toelle Ltr Dtd 990614, 10CFR76.68(a)(3) Decreased Effectiveness Reviews & RAI for Paducah & Portsmouth Transmittals of 1999 Annual Update to Certification Applications ML20210E4291999-07-23023 July 1999 Forwards Required 30-day Written Event Rept Re Unplanned Actuation of C-333-A Autoclave 1 North Autoclave Steam Pressure Control Sys (Aspcs) on 990623.Investigation Ongoing for Root Cause 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217N7591999-10-18018 October 1999 Provides Monthly Update on Progress of Installation of Seismic Upgrade Mods to Bldgs C-331 & C-335 ML20217M3861999-10-15015 October 1999 Provides Addl Changes to SAR Update Certificate Amend Request,Containing Changes That Resulted from re-evaluation of Autoclave head-to-shell O-ring Leakage Analysis Provided by DOE SAR Repts ML20217F6801999-10-12012 October 1999 Forwards Updated Paducah GDP Certificate Amend Requests at NRC for Approval ML20216J8931999-10-0101 October 1999 Forwards Copy of Security Incident Log & Associated Info for Sept 1999 ML20216J9081999-09-30030 September 1999 Forwards Revised Written Event Rept 99-10,rev 3,pertaining to Corroded Fire Sprinkler Heads Affecting Operability of high-pressure Fire Water (HPFW) Sprinkler Sys.No Commitment Contained in Rept ML20217M3701999-09-29029 September 1999 Submits bi-monthly Update on Progress of Mods to Upgrade Audibility of Criticality Accident Alarm Sys (Caas).Schedule for CAAS Audibility Upgrades Attached ML20212H3801999-09-24024 September 1999 Responds to 990723 RAI Re 1999 Annual Update to Certification Applications ML20212H1251999-09-24024 September 1999 Notifies NRC of Change in Regulatory Commitments Associated with Submittal Date for Update of Application SAR Chapter 3.Specifics of Commitment Changes of Listed ML20212H3721999-09-22022 September 1999 Forwards NRC Form 790 Classification Record Documents for Paducah & Portsmouth GDPs That Were Generated During Month of Aug 1999.Without Encl ML20217J1211999-09-20020 September 1999 Submits Listed Comments on NRC Proposed Rule, Reporting Requirements for Nuclear Power Reactors ML20212D4291999-09-17017 September 1999 Forwards Required 30-day Written Event Rept Re Criticality Accident Alarm Sys Response Time in Bldg C-710.Encl 2 Contains Commitments Contained in Submittal ML20212D4231999-09-16016 September 1999 Informs That Review of Event Rept Er 99-12 Revealed Listed Two Statements Inadvertently Omitted from Document ML20212D2361999-09-15015 September 1999 Submits Monthly Update on Progress of Installation of Seismic Upgrade Mods to Bldgs C-331 & C-335 ML20211Q9951999-09-10010 September 1999 Forwards 30-day Written Rept ER-99-12,re Loss of Power to Autoclave Position 1 North & 1 South Process Gas Leak Detection (Pgld) in Bldg C-333-A.Caused by Electrical Short Circuit.Submitted Work Request 501636 for PI SEX-4 ML20216E4891999-09-0909 September 1999 Responds to Violations Noted in Insp Rept 70-7001/99-08. Corrective Actions:On 990602 Responsible Organization Manager Met with FP Engineer Performing Bldg Reappraisal & Made Clear Expectation for Prompt Reporting of Deficiencies ML20211M3551999-09-0101 September 1999 Forwards Copy of Security Incident Log & Associated Info for Month of Aug 1999,IAW 10CFR95.57(b) ML20211K4041999-08-31031 August 1999 Forwards Responses to Remaining NRC Questions/Comments from 980601 & 0709 NRC RAIs Re SAR Update ML20211G9971999-08-26026 August 1999 Forwards Rev 2 to Written Rept Er 99-10,re Corroded Fire Sprinkler Sys in Bldg C-337 & C-333.Analysis of Root Cause Has Not Been Completed.Statistically Based Sprinkler head- Sampling Plan Has Been Completed & Approved ML20211D9751999-08-20020 August 1999 Forwards Rev 1 to Final Written Event Rept Er 99-11,re Unplanned Actuation of C-333-A Autoclave 1 North Autoclave Steam Pressure Control Sys (Aspcs) on 990623 ML20211F1761999-08-20020 August 1999 Requests That Paducah GDP facility,C-709 Lab Annex Bldg Be Added to List of Facilities to Be Exempted from CAAS Detection Coverage ML20211D5811999-08-16016 August 1999 Submits Monthly Update on Progress of Installation of Seismic Upgrade Mods to Bldgs C-331 & C-335 ML20210Q6061999-08-0909 August 1999 Forwards NRC Form 790 Classification Record Documents for Paducah & Portsmouth Gdps,Per 10CFR95.57.Records Were Generated During Month of July 1999.Without Encl ML20210J1331999-07-30030 July 1999 Forwards Copy of Security Incident Log & Associated Info for Month of July 1999,per Reporting Requirements of 10CFR95.57(b) ML20210H3161999-07-30030 July 1999 Forwards Rev 1 to Written Event Rept ER-99-10,re Corroded Fire Sprinkler Heads Affecting Operability of HP Fire Water Sprinkler Sys in Bldg C-337 & C-333.Testing & Analysis of Root Cause & Corrective Actions Necessary Are Not Complete ML20210P7871999-07-29029 July 1999 Provides bi-monthly Update on Progress of Modifications to Upgrade Audibility of Criticality Accident Alarm Sys,In Response to NRC 981217 Request ML20210H2181999-07-29029 July 1999 Responds to Violations Noted in Insp Rept 70-7001/99-07. Corrective Actions:Smoke Watch Was Established Covering Area Affected by Process Gas Leak Detection Inoperabilty & Individuals Involved Were Counseled for Personnel Errors ML20210J7921999-07-27027 July 1999 Forwards Proprietary NRC Form 327, Special Nuclear Matl (SNM) & Source Matl (SM) Physical Inventory Summary Rept, for Paducah & Portsmouth Gdps.Rept Covers Period Ending 990528.Proprietary Info Withheld,Per 10CFR2.790(d) ML20210H6001999-07-26026 July 1999 Forwards NRC Form 790 Classification Record Documents for Paducah & Portsmouth Gaseous Diffusion Plants That Were Generated During Month of June 1999.Without Encl ML20210E4291999-07-23023 July 1999 Forwards Required 30-day Written Event Rept Re Unplanned Actuation of C-333-A Autoclave 1 North Autoclave Steam Pressure Control Sys (Aspcs) on 990623.Investigation Ongoing for Root Cause ML20210C5411999-07-16016 July 1999 Forwards Addl Changes to SAR Update (Sarup) Car,Comprising of Second Set of Sarup Technical Safety Requirement (Tsr) Changes & Associated Changes to Sarup Text Discussed in ML20210C1181999-07-15015 July 1999 Forwards Monthly Update on Progress of Installation of Seismic Upgrade Mods to Bldg C-331 & C-335 ML20210B9701999-07-15015 July 1999 Forwards Proprietary & non-proprietary Info Re Implementation Status of Compliance Plan.Info Covers Period of 990102-0630.Proprietary Info Withheld,Per 10CFR2.790 ML20210B2061999-07-15015 July 1999 Forwards Original Standby Trust Agreement Ack Form.Facsimile of Ack Form Was Submitted in for Usec ML20209G5831999-07-0909 July 1999 Forwards Required 30-day Written Event Rept ER-99-09 Re Loss of Power to Criticality Accident Alarm Sys in Bldgs C-409 & C-720-M.Commitments Made by Licensee Are Identified in Encl 2 ML20209C1041999-07-0202 July 1999 Forwards 30-day Event Rept ER-99-10,re Corroded Fire Sprinkler Heads Affecting Operability of High Pressure Fire Wsater Sprinkler Sys in Bldg C-337 & Bldg C-333.Test to Determine Cause & C/As Necessary Have Not Been Completed ML20209B4541999-07-0101 July 1999 Responds to GL 98-03, NMSS Licensees & Certificate Holders Y2K Readiness Programs, Under Oath & Affirmation for Paducah & Portsmouth GDPs ML20209C1151999-07-0101 July 1999 Forwards Copy of Security Incident Log & Associated Info for Month of June 1999,per Reporting Requirements of 10CFR95-57(b) ML20209D3301999-07-0101 July 1999 Forwards Addl Changes to SAR Update Certificate Amend Request Submitted on 971031,comprising First Set of Technical Safety Requirement Changes & Associated Changes to Text,Which Was Discussed in to NRC ML20209D3511999-07-0101 July 1999 Notifies of Change to Regulatory Commitment Re Mods to C-310 & C-315 Normetex Pump High Discharge Pressure Shutdown Sys, Which Was Made in Response Associated with Table 1,Item 13 of SAR Update Certificate Amend Request ML20209E7141999-07-0101 July 1999 Forwards Security Incident Log & Associated Info for Month of June 1999,per 10CFR95.57(b) ML20209B5531999-06-25025 June 1999 Provides Response to NRC RAI Re Commitment Made During 990624 Conference Call Concerning Request for Enforcement Discretion to Allow Continued Plant Operations Beyond Existing Schedule Date for Issue 36 Noted in DOE/OR-2026 ML20209B5601999-06-25025 June 1999 Forwards Discussion of SAR Changes Made to Address NRC Corrections & Clarifications & Changes Identified by Usec. Revised SAR Pages Encl ML20209D0721999-06-25025 June 1999 Informs That Licensee Intends to Maintain Compliance Plan Issue 2 in Open Status Until NRC Approves Update to Application SAR ML20196E0221999-06-17017 June 1999 Notifies NRC of Change in Regulatory Commitments.Commitments Being Changed Were Made in Usec Ltrs GDP 97-0188 & 97-0189. Specific Changes Are Listed Below ML20196F0151999-06-17017 June 1999 Forwards NRC Form 790,classification Record Documents for Paducah & Portsmouth Gaseous Diffusion Plants That Were Generated During Month of May 1999.Without Encl ML20196A7431999-06-16016 June 1999 Requests Enforcement Discretion to Allow Continued Plant Operations Beyond Existing Schedule Date for Completing Plan of Action & Schedule for Issue 36 Described in DOE/ORO-2026 ML20196A9271999-06-15015 June 1999 Provides Monthly Update on Progress of Installation of Seismic Upgrade Mods to Bldgs C-331 & C-335 ML20196A7311999-06-14014 June 1999 Requests NRC Interpretation to Confirm That Licensee Current Practice of Performing USQ Determination Review to Accomplish Decreased Effectiveness Review of Changes to Safety Programs in SAR Meets Requirements ML20195E9411999-06-0808 June 1999 Provides Results of Initiative to Determine If Further Application of Industry Codes & Stds at Gaseous Diffusion Plants Is Warranted ML20195D5651999-06-0101 June 1999 Provides bi-monthly Update on Progress of Modifications to Upgrade Audibility of CAAS 1999-09-09
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USEC A Global Energy Company l
September 17,1999 GDP 99-1033 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Paducah Gascous Diffusion Plant (PGDP)
Docket No. 70-7001 Event Report ER-99-13 Pursuant to 10CFR76.120(d)(2), enclosed is the required 30-day written event report pertaining to the Criticality Accident Alarm System (CAAS) response time in Building C-710. The Nuclear Regulatory Commission Headquarters (NRC-HQ) operations office was notified of the event on August 22,1999 (NRC No. 36057). Commitments contained in this submittal are identified in.
Any questions regarding this matter should be directed to Larry Jackson at (502) 441-6796.
Sincerely, 1
kIowar Pulley General Manager Paducah Gaseous Diffusion Plant
Enclosures:
As Stated cc: NRC Region III Office NRC Resident Inspector-PGDP W
<Y 9909230118 990917
/
PDR ~ ADOCK 07007001
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C PDR-PO. Box 1410, Paducah, KY 42001 Telephone 502-441-5803 Fax 502-441-5801 http://www.usec.com Offices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC
c l
Docket No. 70-7001 L
GDP 99-1033 i
Page 1 of 5 EVENT REPORT ER-99-13
- DESCRIPTION OF EVENT l
On ' August 21~,1999, at approximately 1824 hrs., the Plant Shift Superintendent (PSS) was notified that during testing of new 30-watt AC/DC Criticality Accident Alarm System (CAAS) horns, in
. Building C-746-Q, the homs did not successfully pass the testing criteria for horn actuation response time of 0.5 seconds, as required by ANSl/ANS Standard 8.3 - 1986. At the time of the testing in Building C-746-Q, the new CAAS horns were not in service and the building remained under the old CAAS system, which remained operable. As a result of the testing in Building C-746-Q and the recognition that the Building C-710 CAAS system used the same 30-watt AC/DC horn, additional testing was performed on August 21,1999, on the Building C-71015-watt AC and 30-watt AC/DC horns. This additional testing indicated that the 30-watt AC/DC horns could not meet the 0.5 seconds time response; however, the 15-watt AC horns did meet the required time response. As a result, on August 21, 1999, at approximately 1955 hrs., the PSS declared the Building C-710 CAAS inoperable and entered the Limiting Conditions for Operation (LCO). On August 22,1999, at 0830 hrs., the. Nuclear Regulatory Commission Headquarters (NRC-HQ) operations office was notified of the event in accordance with 10CFR 76.120(c)(2) (NRC No.
~ 36057).
Prior to 1995, the plan' CAAS horns were the Edwards model 5530-B-N5. In 1995, Safety System t
Inspection Plan 06-999-8310, for electronic horns purchased in accordance with DS-CIE-16289-90, was revised to include a new Edwards model 5530-B-Y6 to the list of acceptable CAAS horns.
The new model horns were considered to be identical to previously accepted models, except that they were designed to function over the full range of 120-240 VAC or VDC. Neither the time response specifications, nor requirements for horn time response testing were included in the specifications for procurement of the Edwards model 5530-B-Y6 horn. It was assumed the Edwards model 5530-B-Y6 would meet the same requirements, because the Edwards model 5530-B-N5 hom had met the time response requirements for an installed CAAS.
On March 8,1996, Engineering Service Order (ESO) Z95820 was initiated to upgrade the Building C-710 CAAS. Analysis indicated that the CAAS building coverage and audibility levels for the building were inadequate. Systems Requirement Document (SRD), ESO Z95820, performance requirements, stated that "the alarm.must sound within 0.5 seconds of the start of the initiating
.)
event."' Design Analysis and Calculations (DAC) Z-95820-3, "LMUS Direction That Alarm Horn Coverage Be Provided For an Area Within 200 Feet of Building C-710" stated that each vendor contacted could supply a horn that would respond within 0.5 seconds.
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Docket No. 70-7001 GDP 99-1033 Page 2 of 5 In 1997, Engineering Specification' Data Sheet (ESDS) DS-CIE-16289-262, " Electronic Alarm Horn Watt," and DS-CIE-16289-90, " Electronic Alarm Horn Watt" were issued. The ESDS identifies requirements for procurement and acceptance. Neither data sheet specified a maximum response time ofless than 0.5 seconds for the homs.
Maintenance Work Package R 9801216-16 was used to document the functional testing for the Building C-710 CAAS project for the five newly installed CAAS clusters and horns. The work package's task description stated, " perform functional / final test for C-710 CAAS project, (5) newly installed clusters." The description of the work performed indicated that on June 28,1998, a functional test was successfully performed in accordance with procedure CP4-GP-IM6239, "C-710 Criticality Accident Alarm System Annual Cluster Replacement and Functional Tests" Section 8.2, for clusters AM, AN, AP, AQ, and AR. On June 29,1998, under this same work package, response time for Building C-710 CAAS design was verified using cluster "AP" with a 15-watt AC hom with acceptable results. This test was performed in accordance with CP4-GP-IM6496,
" Response Time for Criticality Accident Alarm System."
Section 9, " Acceptance Criteria" specifies that an alarm signal shall be produced within 0.5 seconds after initiation.
The new CAAS horns installed in Buildings C-709/710 are of the same manufacture and basic model number; however, some are 15-watt AC and some are 30-watt AC/DC design. At the time of installation, the 30-watt AC/DC CAAS horns were not tested for response time prior to installation. A number of the installed.15-watt AC horns were tested and demonstrated an acceptable response time in accordance with the ANSI /ANS standards. At the time ofinstallation, I
the potential'for a deviation in horn activation response time between the 15-watt and 30-watt horns was not recognized and the 30-watt AC/DC horns were not tested.
i A questioning attitude would have helped determine the existence of a deficiency in the ESDS or
. system testing relative to alarm horn response times. If the 30-watt AC/DC horn response times had been tested, the deviation in actuation times in the two Edwards horn models would have been identified.
The safety significance of exceeding the 0.5 seconds time delay in the actuation of the CAAS horns is considered minimal for the following reasons:
- 1. On August 23, 1999, Engineering Notice EN-C-832-99-037, Rev. O, " Additional Dose Received.By Evacuating Personnel Due To A Delay In CAAS Horn Actuation" was
- published. The evahmtion concluded that the effect of a 1.5 seconds, or less delay beyond the 0.5 seconds allowed by ANS/ ANSI Standard 8.3 in the actuation of the CAAS horn on the dose received by' personnel during evacuation was not significant. On August 24,1999, Health Physics conducted a review of the EN and concluded that there was no increase in consequences due to the additional delay of CAAS horn actuation for 1.5 seconds.
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o Docket No. 70-7001 GDP 99-1033 Page 3 of 5
- 2. On August 25, 1999, Engineering published Engineering Evaluation EV-C-813-99-006, Rev 0, "CAAS Electronic Horn Response Time Test Results (ATRC-99-4990; ATRC 4996).". The EV concluded that a time response to a CAAS alarm can be as much as 1.258 seconds (based on test data) up to 1.758 seconds (based on test data and conversations with
- the vendor). To encompass unknowns, such as how the horn time response will react due to environmental conditions, it was recommended that a maximum 2-second response to a CAAS be implemented.
- 3. On August 25, 1999, Engineering published Engineering Evaluation EV-C-812-99-010, Rev. O, " Evaluation OfImpact of CAAS Alann Horns With Response Times Greater Than 0.5 seconds." The EV concluded that based on a statistical sample testing of the 15-watt AC and 30-watt AC/DC CAAS horns in Building C-710, all of the horns tested allow the system to meet the requirement response time of 2.0 seconds based on the Request For Application Change (RAC) 99C054, Rev. 0, which was approved in accordance with
' 10CFR76.68.
CAUSE FOR THE EVENT A. Direct Cause The direct cause for this event was a failure to include response time testing of the 30-watt CAAS horns in the ESDS, or include the 30-watt horns in the system acceptance testing to assure operability within 0.5 seconds.- At the time ofinstallation, Engineering did not anticipate that a deviation existed in the CAAS horn's activation response times between the 15-watt and 30-watt horns.
B. Root Cause The root cause for this event was an erroneous assumption that the Edwards model 5530-B-Y6 CAAS horn would respond within 0.5 seconds, as existing Edwards model 5530-B-N5 CAAS horns had done. This erroneous assumption resulted in inadequate design testing and control of a critical CAAS horn design characteristic.
CORRECTIVE ACTIONS A. Completed Corrective Actions
- 1. On August 23,1999, Engineering published EN-C-832-99-037, Rev. O, " Additional Dose Received By Evacuating Personnel Due To Delay In CAAS Horn Actuation," which analyzes why the risk is minimal despite a small increase in horn actuation time.
r-Docket o. 70-7001 O JP 99-1033 Page 4 of 5
- 2. On August 25, 1999, Engineering published Engineering Evaluation EV-C-813-99-006, 2
Rev. O, "CAAS Electronic Horn Response Time Test Results (ATRC-99-4990 and ATRC-99-4996)," which shows the CAAS horns meet the newly approved response time of 2.0 seconds.
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- 3. On August 25,1999, The Plant Operations Review Committee (PORC) approved a Request for Application Change (RAC 99C054) in accordance with 10CFR76.68, which changed the Safety Analysis Report (SAR) to accept a CAAS alarm signal within 2 seconds of reaching the alarm setpoint.
- 4. On August 25,1999, Engineering and Maintenance selected and tested a statistical sample of the 15-watt AC and 30-watt AC/DC CAAS horns in Building C-710 in accordance with UE2-BM-PC1038, Rev. O, Change B, " Dedication Of Commercial Grade Items" and CP4-GP-IM6496, " Response Time Testing For Criticality Accident Alarm System, Rev. O. All 15 watt AC and 30-watt AC/DC horns in the sample performed within the 2.0 second requirement.
- 5. On September 2,1999, Engineering revised the following ESDS to add the requirement for a 100 percent test of CAAS horns to verify a maximum response time of 1.5 seconds, or i
less:
- a. DS-CIE-16289-90, Rev. 5, " Electronic Alarm Horn, AC,15-Watt."
- b. DS-CIE-16289-262, Rev. 2, " Electronic Alarm Horn, AC/DC,30-Watt."
- c. DS-CIE-16289-301, Rev. 2, " Electronic Alarm Horn, AC/DC,15-Watt."
B. Planned Corrective Actions
- 1. By November 16, 1999, Engineering will complete a crew briefing for appropriate personnel that will encompass the results of this event and reemphasize the need for a questioning attitude.
- 2. By March 17,2000, Engineering will revise CP2-EG-EG1046, " Design Change Process" to provide additional guidance on development and performance of modification acceptance
' testing of all variations of the design to ensure inputs are met.
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f Docket No. 70-7001 GDP 99-1033 l
Page 5 of 5 l
EXTENT OF EXPOSURE OF INDIVIDUALS TO RADIATION OR RADIOACTIVE I
MATERIAL I
None LESSONS LEARNED i
Testing must be performed on all variations in the configuration of systems, structures, and components to demonstrate that the installed modification will function as the design intended.
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4 Docket No. 70-7001 GDP 99-1033 Page1ofI List of Commitments Event Report ER-99-13
- 1. By November 16, 1999, Engineering will complete a crew briefing for appropriate personnel that will encompass the results of this event and reemphasize the need for a questioning attitude.
- 2. By March 17,2000, Engineering will revise CP2-EG-EG1046, " Design Change Process" to provide additional guidance on development and performance of modification acceptance testing of all variations of the design to ensure inputs are met.
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